fooddrinkeurope guidelines on legibility of labelling · the elements in red are the strokes...

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FoodDrinkEurope Guidelines on Legibility of Labelling February 2012



INTRODUCTION The food and drink industry is committed to helping consumers make informed choices by providing them with accurate, effective and valuable information on pack. However, the demand for space on pack is continuing to increase with requests to provide more and more information at the same time as the amount of space available for this information is decreasing due to the fact that companies are working to reduce packaging for environmental reasons. We recognise that this can cause challenges for the legibility of on-pack information and we are committed as an industry to providing a workable solution to this. Typically a label currently provides the following information:

Name of the food;

List of ingredients (QUID, allergy information, etc.)

Net quantity of the food;

Date of minimum durability and storage conditions;

Name or business name and address of the manufacturer;

Country of origin or place of provenance in certain cases;

Instructions for use, when needed;

Alcoholic strength for alcoholic drinks over 1.2% in strength;

Nutrition information (including GDAs);

Branding;

Promotions;

Consumer communication, etc. FoodDrinkEurope, which represents the EU food and drink industry, has developed this „Code of Practice‟ to provide guidance for manufacturers and enforcement authorities to ensure that all on-pack information is legible. This Code is not intended to be a substitute for legislation but aims to help compliance with the legal requirement to provide legible information by addressing the key factors that determine legibility. This Code sets out recommendations and best practice for the provision of on-pack information. These should be considered collectively and the legibility of information assessed on a case-by-case basis.



LEGAL BACKGROUND Regulation 1169/2011 on the provision of food information to consumers provides in Article 2 a definition for legibility: Article 13 of Regulation 1169/2011 establishes provisions related to certain aspects of legibility, such as a mandatory minimum font size; contrast; background; and positioning; for mandatory food information as per the Regulation. It indicates, amongst others, the following: The Regulation also includes other mandatory provisions related to legibility, for instance the obligation to emphasize the substances or products causing allergies in the list of ingredients (Art. 21). Please note that a general transitional period of 3 years has been foreseen for the application of Regulation 1169/2011, which concretely means that food business operators will have to comply with the rules concerning legibility as of 13 December 2014. Till 13 December 2014, Directive 2000/13/EC on the approximation of the laws of the Member States relating to the labelling, presentation and advertising of foodstuffs will apply. Labelling legibility is also addressed in section 8.1.2 of the General Standard for the Labelling of Prepacked Foods [Codex STAN 1-1985] and in some national legislative texts.

“„legibility‟ means the physical appearance of information, by means of which the information is visually accessible to the general population and which is determined by various elements, inter alia, font size, letter spacing, spacing between lines, stroke width, type colour, typeface, width- height ratio of the letters, the surface of the material and significant contrast between the print and the background.”

Art. 2.2(m), Regulation 1169/2011 on the provision of food information to consumers

“Statements required to appear on the label by virtue of this standard or any other Codex standards shall be clear, prominent, indelible and readily legible by the consumer under normal conditions of purchase and use.”

Section 8.1.2, General Standard for the Labelling of Prepacked Foods [Codex STAN 1-1985]

“[…], mandatory food information shall be marked in a conspicuous place in such a way as to be easily visible, clearly legible and, where appropriate, indelible. It shall not in any way be hidden, obscured, detracted from or interrupted by any other written or pictorial matter or any other intervening material.”

Art. 13.1, Regulation 1169/2011 on the provision of food information to consumers



1. DEFINITIONS A number of terms are used in this Code of Practice. These are defined as follows: Legibility The physical appearance of information, by means of which the information is visually accessible to the general population and which is determined by various elements, inter alia, font size, letter spacing, spacing between lines, stroke width, type colour, typeface, width- height ratio of the letters, the surface of the material and significant contrast between the print and the background; Text is deemed to be legible if it can be easily read by a person with normal visual acuity under good overall conditions (e.g. light and temperature effects). Typeface Typeface is the style of lettering, such as Helvetica or Times. Serif typeface Serifs are the non-structural details on the ends of some of the strokes that make up letters and symbols. A typeface that has serifs is called a serif typeface (or seriffed typeface). Examples of serif typefaces are Times New Roman and Courier.

Figure 1: Example of Serif typeface

The elements in red are the strokes mentioned above. Sans serif typeface A typeface without serifs is called sans-serif, from the French “sans”, meaning “without”. Some typography sources refer to sans serif typefaces as "grotesque" (in German "grotesk") or "Gothic," and serif types as "Roman." These terms are no longer commonly used however, except in specific font names. Examples of Sans serif typefaces are Helvetica and Verdana.



Figure 2: Example of Sans serif typeface

AaBbCc Font Font is the set of a typeface used to produce the letters. For example, Helvetica, point 12 and Helvetica, point 14 are different fonts even though both have the same typeface. Point Point is the standard unit of measure used to specify font sizes. Many different conversion scales exist for the point size:

ATA = 0.3514598 mm Didot = 0.3759 mm IN = 0.4 mm PS or DTP = 0.3527777778 mm TeX = 0.3514598035 mm

Font size (point size) The font size is the height of a character from the lowest descender to the highest ascender.

Figure 3: Font size

The ascenders are the parts of the characters that lie above the meanline. The descenders are the parts of the characters that lie below the baseline. Font height The font height is the actual height of characters such as H or k, from the baseline to the top of the ascender. It is typically 72 % of the font size.



Letter height (x-height or corpus size) The letter height is the distance between the baseline and the mean line in a typeface. Typically, this is the height of the letter „x‟ in the font. Whether two fonts appear to have the same height is primarily determined by whether their x-heights match. Characters with rounded shapes (called 'bowls'), such as c, o, e, are always drawn larger than letters with flat upper and/or lower surfaces (for example, v, w, x, z). The reason is that, if lower-case letters with bowls were drawn to the same vertical dimension as x they would look smaller to the human eye. Figure 4: Examples of x-height in relation with the font size of 6 points and different typefaces

Same font size (6 pt) in relation with different typefaces x-height FONT SIZE

Arial Narrow Avant Garde

Aldus

6 pt Ingredient x 1.098 mm Ingredient x 1.157 mm

Ingredient x 0.924 mm

Same x-height (1.2 mm) in relation with different typefaces font sizes

X-HEIGHT

Arial Narrow Avant Garde

Times New Roman

1.2 mm Ingredient x 6.672 pt Ingredient x 6.252 pt

Ingredient x 7.992 pt



Tracking (character spacing) Tracking is the horizontal space added to or subtracted from the space between characters in a text. Figure 5: Tracking Leading (interlinear spacing) Leading is the vertical spacing between the lines of text. The name comes from the physical piece of lead that used to be used in mechanical printing process to separate lines of text (see figure 5). Symbols A symbol is something - such as an object, picture, written word, or particular mark - that represents (or stands for) something else by association, resemblance, or convention, especially a material object used to represent something invisible. Symbols indicate (or serve as a sign for) and represent ideas, concepts, or other abstractions. Largest surface area The largest surface is the single largest area of the package that can be seen from a single point of view and that can be printed on from a technical perspective. Generally, it is the largest surface bounded/limited by edges. For surfaces without such, e.g. in the case of cylindrical or conical packages, the curvature has to be taken into consideration when calculating the available area. For instance, the largest surface of a can corresponds to approximately 1/3rd of the round surface of the can. Furthermore, as there are many different shapes of packs other than boxes and cylindrical/conical packages, these specificities should be taken into account on a case-by-case basis. The food business operator should ensure that the mandatory food information that is provided is clearly legible and easily accesible for the consumer.



2. LEGIBILITY FACTORS AND RECOMMENDATIONS

Legibility is determined by a number of inter-related factors including layout, font, colour, contrast, packaging/ label material, packaging shape, printing techniques etc. No one factor can determine the overall legibility of the information. These factors should be considered collectively and the legibility of information assessed on a case-by-case basis. Furthermore, given that reader dependant factors and environmental factors can affect the legibility of a label, it must be assumed that the reader has a normal visual acuity and is viewing the information under good overall conditions. The recommendations in this Code of Practice have been grouped into the following categories:

Lay-out;

Font, colour and contrast;

Packaging and printing. 2.1 LAY-OUT The layout of information can have an impact on legibility. Given the wide variety of packaging sizes and shapes, no single ideal layout exists but there are a number of factors that should be taken into consideration when determining legibility, in particular titles/headings, blocks of information, text alignment and use of symbols. Titles and headings Headings can help direct consumers towards specific information and to separate text if space permits. DO! Distinguish the text for headings by, for example, using bold type

and/or upper case text

DO! Making headings clear, short and consistent, for example: - Ingredients; - Preparation or Cooking Instructions; - Storage; - Etc. -

CARE! Extensive use of upper case and underlining



Figure 6: Example of title highlight (bold) for the list of ingredients

Figure 7: Example of title highlight (separated heading) for the Cooking Instruction

Blocks of information

DO! Where space allows, group information, which belongs together

DO! Where appropriate, separate different groups of information with frames or boxes



Figure 8: Example of blocks of information (separated with a frame) for the list of ingredients and recommendations of use

Text alignment

DO! Text should start and be aligned with the left margin;

DON’T Avoid placing information in circles

DON’T Avoid placing a large amount of text with only one or two words on each line

Figure 9: Example of text alignment



Use of symbols

Simple, recognisable, functional symbols can help save label space and direct the reader to information. Please note that several logos, where used, have to follow mandatory requirements as prescribed by EU legislation (e.g. the EU Organic logo, identification marks for products of animal origin, etc.). DO! Obvious symbols can be used, for example for storage,

preparation and cooking instructions;

DO! Related advice should be displayed close to the symbols;

DON’T Too many or overly complex symbols can fail because they try to do too much. It is therefore important to get the balance right.

Figure 10: Example of effective use of symbols

Figure 11: Example of effective use of symbols



2.2 FONT, COLOUR AND CONTRAST The appearance of the font can have an impact on legibility. There are a number of factors that should be taken into consideration when determining legibility in particular font size, character spacing, choice of font, colour, contrast and visual background noise. Font Letter height The generally accepted method for determining letter height is by reference to the x-height as this provides the specific measurement of two reference points of the letter. Point size is not used because the same point size can result in different letter heights depending on the typeface used and font sizes/font heights are not used because of the difficulty in identifying the reference points for the measurement of letters. There is no pre-established ratio between the x-height and a font size. Nevertheless, an x- height of 1.2 mm is approximately equivalent to 7.2 point size Arial and this equates to a font size of between 2.5 mm – 2.7 mm. DO! As a basic principle try to use as large a letter height (x-height) as

possible

CARE! In accordance with EU Regulation 1169/2011, for packages or containers with the largest surface of 80 cm

2 or higher, a minimum

font size of 1.2 mm is required for the mandatory particulars prescribed in the Regulation.

CARE! Where the largest surface area is smaller than 80 cm², a minimum

font size of 0.9 mm is required by Regulation 1169/2011 for the mandatory particulars prescribed in the Regulation. Please note that small packs and containers with the largest surface of less than 10 cm2 may bear fewer mandatory particulars.

Tracking (character spacing) Adequate character spacing is an important factor for legibility as characters too close together prevent the reader from recognising the letters. DON’T!

It is recommended that characters should not be condensed by more than 1pt.



Figure 12: Example of character spacing: normal and condensed by 1.2pts

Leading (interlinear spacing) DO! It is recommended that the line space should be 120% of the point

size. For example, 6 point font should be set with 7,2 point leading.

DO! In cases where this is not possible, the minimum recommended line space is 0.5 point more than the point size. In this context, it is important to consider the fact that the x-height, weight of type (whether it is bold or not), case or line length can impact the perception of inter-linear spacing.

DO!

Fonts with proportionally larger x-heights need more inter-linear spacing.



Figure 13: Example of inter-linear spacing of 11.5pt and 10 pt.

Font Selection DO!

Sans serif faces (e.g. Arial, Helvetica, Myriad, Frutger, Univers) are generally preferable, or those serifed faces that have a large bowl size and work well at a small size

DO! It is important to ensure that numbers are distinct. Numbers can easily be misread in certain typefaces (particularly the numbers 6, 8 and 9 in Arial).

CARE!

Stylised, ornamental, decorative fonts can be hard to read and should be used with care.



Figure 14: Example of Sans Serif Font (Arial – 9pts) and Serif Font (Times New Roman – 9pts)

Colour, Contrast, Visual Background Noise DO! While the choice of colours may often be dictated by their use in the

brand, it is essential that the contrast between text and background is as high as possible. It is recommended that the selected colours clearly contrast.

CARE!

Subtle contrasts, shadowing and 3D effects can reduce legibility and should therefore be used with care and avoided where possible.

CARE!

Busy images, pictures, patterns and watermarks may create visual background noise, and should therefore be used with care and avoided where possible.

CARE!

If the packaging is transparent, a good contrast is needed with the food product forming the visible background.



Figure 15: Example of use of colours, contrasts and visual background noise

2.3 PACKAGING

Packaging technique Information should not be printed in areas of the package where it would be difficult to read, in particular, in areas, which are not directly accessible and require the packaging to be opened in order to read the information. Below are some examples of situations where extra care should be taken to ensure legibility.



DO! Give preference to matt finish printing surfaces.

CARE!

Deformation zones of sleeves or 3 dimensional surfaces and other thermoform packaging techniques

CARE!

Heat sealed areas (for example ends of the wrappers of bar products);

CARE!

Plastic shrink-wrap.

Packaging material

The packaging material and print finishes can have an impact on legibility. CARE!

Be aware that high gloss surfaces might increase glare and therefore greater attention needs to be given to contrast as well as the appropriate printing technique.

CARE!

Be aware that the shape of the packaging can increase glare.

Figure 16: Example of effective printing on a curved shaped package



3. SUMMARY TABLE – BEST PRACTICES FOR LEGIBILITY

Recommended Use with care Best Avoided

Layout - Headings to be clear, short and consistent;

- Use bold type and/or upper case text to distinguish headings;

- Where space allows, group information which belongs together;

- Where appropriate, separate different groups of information with frames or boxes;

- Text should start and be aligned with the left margin;

- Use symbols to help reduce the quantity of text and direct the reader to information.

- Extensive use of upper case and underlining;

- Text in other format than blocks; - Text wrapping; - Centre alignment; - Text aligned with the right

margin;

- Over hyphenation of text; - Blocks of texts without

headings, titles or any separation;

- Placing a large amount of text with only one or two words on each line;

- Placing the information in circles;

- Too many or overly complex symbols.

Font, Colour and Contrast

- Comply with the requirements in Regulation 1169/2011, including minimum font size

- Adequate character spacing; - Inter-linear spacing of 120%

of the font size; - Easy-to-read (sans serif)

fonts; - Choose a typeface designed

for use at small font size; - Clearly contrasting colours

- Inter-linear spacing of less than 120% of the font size

- Italic; - Serif typefaces; - Stylised, ornate decorative

fonts; - Subtle contrasts, shadowing, 3D

effects, watermarking or non- uniform background.

- Where packaging is transparent, good contrast is necessary with food product forming the visible background.

- Character spacing condensed by more than 1 pt;

- Inter-linear spacing of less than 0,5pt more than the font size;

- Colours with similar tonal contrasts - light type on a light background or dark type on a dark background.

Packaging/ Printing

- High quality printing - Printing on deformation zones; - Heat sealed areas; - Plastic shrink wrap; - Metallic and shiny printing

surfaces; - Labels printed on curved

surfaces.

- Zones of the packaging which are not directly accessible;

- Areas where the destruction of the package is required to read the text.

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